Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court in this case involving a challenge to one party's failure to abide by a provision in the parties' contract, holding that Plaintiff was not entitled to relief. Kiernan Family Draper, LLC (Kiernan) and Hidden Valley Health Center, LC and Hidden Valley, LLC (collectively, Hidden Valley) collaborated to develop their neighboring properties into a shopping center and entered into a declaration of covenants, conditions, and restrictions. At issue was the declaration's statement that a certain number of parking spaces would be provided and the antiwaiver provision stating that a party's failure to enforce a provision of the declaration shall not be construed as a waiver. Fifteen years after Hidden Valley finished construction on its parcel Kiernan sued, challenging Hidden Valley's failure to provide the required parking spaces. The district court applied the statute of limitations to bar Kiernan from enforcing the parking ratio as written in the declaration and in limiting Kiernan's recovery to the post-construction "status quo." The Supreme Court affirmed, holding (1) the declaration's antiwaiver provisions preserved the parking provision despite Kiernan's delay in bringing suit; (2) the statute of limitations barred Kiernan from enforcing the parking provision as written; and (3) Kiernan's claim was subject to the statute of limitations even though it alleged harm to a property right. View "Kiernan Family Draper v. Hidden Valley" on Justia Law

The Supreme Court vacated the determination of the court of appeals that R. Scott National, Inc. (RSN) was an "agent" of Pacific Life Insurance Company (Pacific Life) based on Utah Code 31A-1-301(88)(b), and therefore granting partial summary judgment to Plaintiffs on their claim that Pacific Life should be held liable for RSN's alleged misdeeds, holding that remand was required.The district court granted summary judgment to Pacific Life, concluding that nothing RSN did was within the actual or apparent authority Pacific Life granted RSN. The court of appeals reversed and granted partial summary judgment for Plaintiffs, holding that RSN was Pacific Life's agent and that RSN's actions fell within the scope of authority Pacific Life had granted RSN. The Supreme Court vacated the judgment below, holding that the court of appeals (1) erred in ruling that section 31A-1-301(88)(b) made RSN an agent of Pacific Life and in injecting respondeat superior principles into Utah Code 31A-23a-405(2); and (2) Plaintiffs were entitled to the entry of partial summary judgment on the issue of RSN's apparent authority from Pacific Life. View "Drew v. Pacific Life Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Petitioner's post-conviction challenge to his convictions of child sex abuse and other offenses as time-barred under the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101-503, holding that Petitioner's arguments on appeal were unavailing.Petitioner filed a petition pursuant to the PCRA the district court for post-conviction relief from his criminal conviction and sentence. The district court granted summary judgment for the State, concluding that the petition was time-barred under the PCRA. Petitioner appealed, arguing that the PCRA's time limitations should be tolled or, alternatively, he can invoke the court's constitutional writ power outside the PCRA. The Supreme Court affirmed, holding (1) the PCRA time-barred Petitioner's petition; and (2) Petitioner failed to demonstrate that the application of the time-bar contained in the PCRA to Petitioner's petition violated his rights under the Utah Constitution. View "Patterson v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals ruling that the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101-110, barred Appellant's claims because they "could have been" brought on appeal, holding that Appellant's claims failed because trial counsel was not ineffective.Appellant was convicted of sexually molesting his daughter. The convictions were affirmed on appeal. Appellant later filed a petition for post-conviction relief, arguing that his trial counsel was ineffective and that his appellate counsel was ineffective for failing to raise ineffectiveness claims on direct appeal. The reviewing court denied relief. The court of appeals affirmed, ruling that the PCRA barred Appellant's claims. The Supreme Court affirmed, holding (1) the PCRA barred Appellant's direct claims against his trial counsel; and (2) appellate counsel was not ineffective. View "McCloud v. State" on Justia Law

In this personal injury action, the Supreme Court affirmed the judgment of the district court granting summary judgment to the United Parcel Service, Inc. (UPS) and concluding that the negligence of KNS International, LLC was a superseding cause of Plaintiff's injury, holding that summary judgment was appropriate.Stuart Wood, a truck driver, was picking up packages from a KNS warehouse when a heavy vinyl curtain fell from the loading bay door above Wood's head and hit him, causing serious injuries. The curtain had been jarred loose after an accident that had occurred one week early when a UPS truck had backed into the loading bay and struck the building. Wood and his wife filed suit against KNS and UPS. The district court granted summary judgment for UPS. The court of appeals affirmed, concluding that UPS owed Wood no duty by the time he was injured. The Supreme Court affirmed on different grounds, holding that summary judgment was appropriate because KNS's actions were a superseding cause of Wood's injury. View "Wood v. United Parcel Service, Inc." on Justia Law

The Supreme Court reversed the interlocutory order of the district court denying Cathy McKitrick's motion to dismiss Kerry Gibson's petition for judicial review of the decision of the Ogden City Records Review Board granting McKitrick's request for government records, holding that a statutory claimant who lacks statutory standing may not proceed on the basis of traditional or alternative standing.McKitrick, a freelance journalist, sought records related to an investigation into the alleged official misconduct by Gibson, a former Weber County Commissioner. After the Review Board granted the records request Gibson petitioned for judicial review. McKitrick filed a motion to dismiss, arguing that Gibson lacked standing under the Utah Governmental Records Access and Management Act to seek judicial review of the appeals board's access decision. In response, Gibson argued that his petition should proceed because he met the tests for both traditional and public interest standing. The district court denied the motion to dismiss. The Supreme Court reversed, holding that a statutory claimant must have statutory standing, and the presence of traditional or alternative standing will not cure a statutory standing deficiency. View "McKitrick v. Gibson" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of lewdness by a sex offender and vacated the conviction, holding that the court of appeals erred in upholding the district court's admission of other acts evidence.During trial, the State sought to introduce evidence of four prior occasions when Defendant had been accused of exposing and/or stimulating himself in public. The district court admitted the evidence over Defendant's objection, concluding that the doctrine of chances permitted the State to introduce the evidence. The court of appeals affirmed. The Supreme Court reversed, holding (1) if the doctrine of chances is remain part of this jurisprudence, it needs to be more carefully explained and more precisely employed; and (2) the doctrine of chances was not correctly applied to admit the evidence in this case. View "State v. Richins" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that it lacked jurisdiction over this challenge to the rejection of a referendum application, holding that the district court erred in its interpretation of Utah Code 20A-7-602.8(4)(a) and its conclusion that it lacked jurisdiction.Appellants, residents and registered voters of Morgan County, filed an application to submit an ordinance approving the development of a ski resort community to a referendum. The county clerk rejected the referendum application. Appellants then filed in the district court a petition challenging the rejection of the proposed referendum. The district court dismissed the challenge for lack of jurisdiction based on its reading of section 20A-7-602.8(4)(a). The Supreme Court reversed, holding (1) sponsors are prohibited from pursuing an extraordinary writ in the Supreme Court under section 602.8(4)(a) when they cannot satisfy the requirements of Utah R. App. P. 19; and (2) Appellants in this case appropriately raised their challenge in the district court. View "Croft v. Morgan County" on Justia Law

The Supreme Court remanded this case to the district court for further proceedings, holding that, as a matter of law, a boat manufacturer or supplier owes a duty to adequately warn passengers of dangers associated with the failure to wear a stop switch lanyard.Craig Feasel was severely injured when he and the driver of a boat, Monty Martinez, were ejected into the water. Martinez was not wearing the stop switch lanyard at the time of the ejection. Feasel argued that Defendants - the boat manufacturer and the engine manufacturer - were liable for his injuries because they failed adequately to warn the driver of the danger associated with failure to wear the lanyard and failed in their duty to warn boat passengers of the danger. The district court granted summary judgment for Defendants. The court of appeals reversed. The Supreme Court remanded the case, holding (1) the standard for determining the adequacy of a warning is that the warning must be of an intensity and at a level of specificity justified by the magnitude of the risk; and (2) this Court adopts a standard of reasonableness to determine whether warnings regarding the dangers of not wearing a lanyard must be issued directly to the passenger or an intermediary may be relied upon to convey the warnings. View "Feasel v. Tracker Marine LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court denying a wellness company's motion to dismiss this breach of contract action brought by an independent distributor, holding that the distributor's allegation of an express oral waiver was legally sufficient to defeat a motion to dismiss.In its complaint, the distributor claimed that the company had waived - through express oral statements and conduct - the provision upon which it later relied to terminate the distributor's contract. In moving to dismiss the complaint, the company argued that where the contract contained both an antiwaiver provision and a requirement that any waiver be in writing, the distributor's claims were insufficient as a matter of law to waive a provision of the contract. The district court denied the motion to dismiss. The Supreme Court affirmed, holding (1) a contracting party alleging waiver must show the other party intentionally waived both the underlying provision and any applicable antiwaiver provisions; and (2) the alleged facts, taken as true, were sufficient to infer that the company waived the underlying provision and the applicable antiwaiver provisions. View "Al-In Partners, LLC v. LifeVantage Corp." on Justia Law